Key Takeaways

Any obligated producer can be selected for an EPR audit — the Environment Agency and compliance schemes both conduct audits.
Auditors check your packaging data accuracy, material classifications, tonnage calculations, and supporting evidence.
The most common audit finding is inaccurate data — either under-reporting (missing packaging) or incorrect material classification.
Maintaining a packaging register with supporting weight evidence is the single most important preparation step.
Audit non-compliance can result in penalties, fee adjustments, and increased scrutiny in future years.

What Is an EPR Audit?

An EPR audit is a formal review of your packaging data and compliance processes. Auditors verify that the data you submitted through DEFRA’s RPD portal is accurate and that you are meeting your obligations as an obligated producer.

Audits can be conducted by:

The Environment Agency (or equivalent regulators: SEPA, NRW, NIEA)
Your compliance scheme (if you use one)
PackUK or their appointed auditors

Audits may be triggered randomly, based on risk profiling, or following a complaint or data query.

For background, see what packaging EPR is.

Who Can Be Audited?

Any obligated producer can be audited. However, certain factors increase the likelihood:

Large producers (over £2M turnover, 50+ tonnes) are more likely to be audited
Significant year-on-year changes in reported data may trigger a review
New registrants may receive a compliance visit
Sectors with known compliance challenges may be targeted
Previous non-compliance increases the likelihood of repeat audit

What Auditors Check

1. Registration Accuracy

Is your registration information correct and up to date?
Are all relevant subsidiaries and trading names included?
Is your turnover and tonnage correctly declared for producer classification?

2. Data Accuracy

Does your reported tonnage match your supporting evidence?
Are material classifications correct?
Is packaging category classification (primary/secondary/transit) accurate?
Is nation data allocation reasonable and supported?

3. Completeness

Have you reported ALL obligated packaging?
Are there packaging types you have missed?
Have you included service packaging, transit packaging, and imported packaging?

4. Methodology

How do you collect packaging data?
What weighing methodology do you use?
How do you calculate annual tonnage from sample data?
How often do you update your data?

5. Activity Classification

Have you correctly identified your packaging activities?
Are you reporting packaging that should be another party’s obligation?
Are you failing to report packaging that IS your obligation?

Documents You Need

Have the following ready before an audit:

Essential Documents

Document	Purpose
Packaging register	Master list of all packaging components with materials and weights
Weight evidence	Physical weighing records, supplier specifications
Sales/dispatch data	Proof of volumes sold/dispatched
Import records	Customs data for imported goods
Procurement records	Purchase orders for packaging materials
RPD submissions	Copies of data submitted to DEFRA
Compliance scheme membership	Registration confirmation

Supporting Documents

Document	Purpose
Product photographs	Showing packaging configurations
Supplier packaging specs	Technical specifications from packaging suppliers
Nation data methodology	How you calculated geographic distribution
Packaging change log	Record of packaging changes during the reporting period
Internal audit records	Any self-assessments you have conducted

Nice-to-Have

Process flowcharts showing how packaging data is collected
Job descriptions for staff responsible for EPR compliance
Training records for staff involved in data collection
Previous audit reports and corrective actions

Common Audit Findings

1. Under-Reported Tonnage

The issue: Missing packaging types that should be included Common causes: Forgetting transit packaging, labels, tape, or service packaging How to prevent: Use a comprehensive packaging weight audit checklist

2. Incorrect Material Classification

The issue: Reporting packaging under the wrong material type Common causes: Classifying fibre composites as paper/card, confusing steel with aluminium How to prevent: Physical inspection and material testing

3. Outdated Weight Data

The issue: Using old packaging weights when packaging has changed Common causes: Not updating records after packaging redesigns How to prevent: Update your register whenever packaging changes

4. Incorrect Activity Classification

The issue: Reporting packaging under the wrong activity type Common causes: Not understanding the importer vs seller distinction How to prevent: Review your activity classification annually

5. Weak Supporting Evidence

The issue: Cannot demonstrate how tonnage figures were calculated Common causes: Relying on estimates without documented methodology How to prevent: Maintain weighing records, photographs, and calculation spreadsheets

Preparing Your Team

Before the Audit

Brief your EPR data owner on the audit process and likely questions
Review your data against supporting evidence — identify and fix any discrepancies
Organise your documents — have everything accessible, not buried in filing cabinets
Walk through your methodology — can you explain how each number was derived?
Check recent packaging changes — are they reflected in your data?

During the Audit

Be honest and transparent — auditors understand that EPR is complex
Provide requested documents promptly — delays create a negative impression
Explain your methodology clearly — auditors want to understand your process
Ask questions if you do not understand what is being requested
Take notes — record what was discussed and any findings

After the Audit

Address any findings promptly — implement corrective actions
Update your data if errors were identified
Improve your processes based on auditor recommendations
Document what you changed — this shows good faith in future audits

Getting Started

Conduct a self-audit using the EPR compliance checklist
Review your packaging register for completeness and accuracy
Verify weight data against physical samples
Organise your evidence files — one folder per reporting period
Brief your team on roles and responsibilities

Visit our pricing page for tools that help maintain audit-ready compliance data.

How to Prepare for an EPR Audit

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